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On September 06, 2011, the Federal Court of Appeal is scheduled to hear an appeal by Saipem UK Limited (“Saipem UK”) against a decision of the Tax Court of Canada interpreting Article 22 of the Canada-UK Tax Treaty
The United Kingdom is now seriously considering the introduction of a form of GAAR after having relied for years on judicial doctrines of anti-avoidance as expounded in such cases as WT Ramsay Ltd v. IRC, 1981 STC 174 (HL); CIR v. Burmah Oil Co. Ltd., 1982 STC 30 (HL); Furniss v. Dawson, 1984 STC 153 (HL); Craven v. White, 1988 STC 476 (HL); Ensign Tankers (Leasing) v. Stokes (HMIT), 1992 STC 226 (HL
When a government employee uses workplace email to send and receive personal email, are those emails subject to disclosure under access to information laws?
